Mandatory e-invoicing system

E-invoicing is currently permitted through the national e-invoice exchange platform launched by the Ministry of Digital Economy and Entrepreneurship (MDEE) in 2019.  This platform allows taxpayers to issue invoices directly or connect via API if they have their own invoicing software. 

 Jordan is likely to move toward mandatory e-invoicing soon. The government is expected to release the implementation roadmap and technical requirements in 2023. 

Wave 7 of Phase 2 e-invoicing

The ZACTA (Zakat, Tax and Customs Authority) has defined the criteria for the seventh wave of phase 2 of the e-invoicing mandate. 

From February 1, 2024, taxpayers with VAT taxable revenue over SAR 50 million for the years 2021 and 2022 must integrate their e-invoicing systems with ZATCA (FATOORA).  

Mandatory B2B ‘e-billing system’ by July 2025

The Ministry of Finance announced that the UAE is planning to develop a new advanced E-Billing system for B2B transactions. The new system will be integrated in different phases with complete integration by July 2025.  

It is not known what the “e-billing system” will look like, but it is likely UAE will adopt a similar CTC approach to KSA. 

E-invoicing guidelines published by IRB

Following the announcement of the implementation timeline for the e-invoicing mandate, the Inland Revenue Board of Malaysia (IRBM) has issued the first version of the E-invoice Guideline Year 2023 which contains additional clarifications and instructions on the upcoming e-invoicing mandate in July 2024. 

The mandate will follow a CTC clearance model, where suppliers must transmit their invoices and have them approved by the government platform before sending them to their buyers.   

According to the guideline, suppliers can connect directly with the government portal, or integrate their invoicing system via API connections. The invoices transmitted to the platform must be in XML, or JSON format. After successfully “clearing”, the official platform will send back the cleared invoice with a Unique Identifier Number and QR code data.  

Suppliers can share the invoice in PDF format provided the UIN number and QR code are presented. In addition, the guideline outlines 53 mandatory invoice fields. For more details, we advise you to check the full guideline via this link. 

E-invoicing obligations for new wave of taxpayers

Last month, Kofax commented on Bolivia’s e-invoicing expansion, which stretched to a fifth group of taxpayers. The e-invoicing drive continues apace, with the Bolivian government now announcing a sixth group of taxpayers to be subject to e-invoicing obligations.  

Resolution N° 102300000020 imposes e-invoicing commitments on further taxpayers, who will now be obliged to issue e-documents.  

The requirement to comply will take effect from 1 September 2023. 

Following the format of the earlier resolution, impacted taxpayers can find further details in the resolution annex. 

E-invoicing regulations for new wave of taxpayers

Only last month saw Bolivia accelerate its e-invoicing drive, with the eventual intention of concluding its e-invoicing roll-out in the country. Relatively close Panama is now also imposing fresh e-invoicing obligations on further taxpayers. 

Resolution N°201-0806, published by the General Directorate of Revenue (DG), confirmed that impacted taxpayers who provide services relating to ‘stock exchange, brokerage houses, investment managers, advisors of investments and price providers’ must now adhere to the Electronic Billing System in Panama.  

Impacted taxpayers must comply with e-invoicing obligations from 31 August 2023.  

The measure is part of a wider e-invoicing initiative to bring further taxpayers under the scope of the regime. You can read more about e-invoicing in Panama on our dedicated country-specific page here 


Carta Porte sanction extension

Mexico has been in the midst of some turbulent e-invoicing changes, the most notable being the transition to the CFDI 4.0. Kofax supports the CFDI 4.0 as part of our e-invoicing solution today. 

For specific transportation goods, the Mexican government also imposes further obligations on Mexican taxpayers, who are required to process the ‘Carta Porte’ as part of its CFDI. Kofax has successfully supported the Carta Porte since January 2022.  

Coinciding with the Carta Porte launch, the Mexican government initially afforded some concessions to Mexican taxpayers, allowing a grace period whereby taxpayers would not been sanctioned for missing or inaccurate information in the Carta Porte. This owes largely to the complexities associated with the Carta Porte and its relatively fast implementation.  

These concessions have now been extended to 31 December 2023. 

From 1 January 2024, penalties will come into effect, meaning taxpayers will need to ensure information contained within the Carta Porte is accurate and complete, to avoid sanctions. 


European Union Council derogation approval

Only a few weeks ago, Kofax’s recent post commented on the European Union’s draft proposal to authorise Romania to mandate B2B e-invoicing in the country.  

And e-invoicing advancements are developing swiftly. The Council of the European Union has now approved this request, authorising Romania to mandate B2B e-invoicing in the country. The timeframes for approval remain the same as previously communicated- i.e., from 1 January 2024 to 31 December 2026, or alternatively, when Digital Reporting Requirements for ViDA come into effect.  

The EU approval can be located via the link below: 

The derogation approval represents a significant milestone for Romania’s e-invoicing trajectory. However, while Romania’s e-invoicing mandate is projected for 1 January 2024, this date is certainly not set in stone, and there are already tentative indications that this may be delayed. Kofax is closely monitoring e-invoicing developments in the country.  

Small Medium Enterprise (SME) B2G e-invoicing – further delay

Portugal’s B2G Small and Medium Enterprise (SME) mandate has been subject to multiple revisions- and yet again, this has been delayed – to 31 December 2023, via Law Decree no. 54/2023. 

Current requirements in Portugal mandate that only large businesses have a requirement to issues e-invoices in the B2G e-invoicing environment. 

You can read more about B2G e-invoicing in Portugal on our dedicated country-specific page here 


‘Growth Opportunity Act’, including e-invoicing delay

Germany’s April 2023 discussion paper had proposed a 1 January 2025 start date for the inception of the country’s B2B e-invoicing mandate.  

As is the case with other e-invoicing mandates however, mandate inception dates will always be subject to revision and influenced by externals factors- such as public readiness for the mandate, amongst others.  

Germany’s ‘Growth Opportunity Act’ has responded to the concerns raised in the public consultation regarding the inception date and has, for now, re-instated the mandate inception date to 1 January 2026. 

 In other important timeframes communicated:   

  • E-invoicing will still be possible from 1 January 2025, although, in line with current regulations, recipient consent for e-invoicing will be required. However, paper, PDF and other invoice forms will still be permissible in 2025. 
  • All structured e-invoice formats, including EDI, will be permitted up to 31 December 2027.  
  • From 1 January 2028, structured formats must adhere to the EU common standard. 
  • Presently, simplified invoices are expected to be precluded from Germany’s mandate. 

EDI has a robust following in Germany, particularly in the automotive and manufacturing industries. Adherence to the EU standard may accomplish harmonisation- but will be at odds with Germany’s powerful EDI following. It is inevitable that the question of the EU standard will come under scrutiny, especially given the proposed limitations post January 2028. 

It is important to note that the ‘Growth Opportunity Act’ is a draft bill only. Kofax is still waiting for the BMF to provide final technical specifications which will provide a definitive reflection of Germany’s mandate. 


Legislative amendments to accommodate e-invoicing

The German Ministry of Finance (BMF) April 2023 discussion paper provided a good indication of Germany’s projected e-invoicing model. However, Germany’s legislative divisions have also been working to accommodate the mandate and cement e-invoicing into the country’s legislative framework.  

Draft amendments to the country’s Value Added Tax Law, Umsatzsteuergesetz (or UStG) are currently being drafted in Germany, which will provide the critical foundation for establishing e-invoicing in the country. 

More specifically within the legislation, the definition of an e-invoice is limited to that which is: 

  • issued and received in a structured format, and 
  • is compliant with the EU e-invoicing standard, the EN16931.  

The legislative draft amendments therefore align the definition of an e-invoice more robustly with the ideology expressed in the VAT in the Digital Age proposal 

Please refer to this month’s update, ‘Growth Opportunity Act, including e-invoicing delay’ for further information concerning Germany’s e-invoicing timeline.  

European Union Council derogation approval

Only a few weeks ago, Kofax’s recent post commented on the European’s Union’s draft proposal to authorise Germany to mandate B2B e-invoicing in the country.  

And e-invoicing advancements are developing swiftly. The Council of the European Union has now approved this request, authorising Germany to mandate B2B e-invoicing in the country. The timeframes for approval remain the same as previously outlined in the draft- i.e., from 1 January 2025 to 31 December 2027, or alternatively, when Digital Reporting Requirements for ViDA come into effect.  

The EU approval can be located via the link below:  

The derogation approval represents a significant milestone relating to Germany’s e-invoicing trajectory. Germany is a critical market for Kofax, and we are closely monitoring e-invoicing developments in the country.  

Mandatory e-invoicing legislation approved

Though the Polish e-invoicing legislative process has been an extensive one, to date it has not been subject to significant resistance in the Polish Parliament, the Sejm.  

Despite this, Senators in the Lower House rejected the mandatory e-invoicing legislation in Poland. While ostensibly perceived as an obstruction, the rejection was attributed to political fractures between the higher Senate and Sejm Chambers rather than pertaining to the actual legislative content. This was not expected to impede the e-invoicing legislative progress, and the legislation will now proceed to the Upper House, which holds the prerogative to overrule the Lower Chambers.  

The law has subsequently been passed and will now proceed to the President for final signature.  

Kofax looks forward to analysing the final Polish e-invoicing legislation, which is expected in Q4 2023. Major revisions to the current legislation are not expected, alongside the final FA2 schema, which also presented minimum amendments.  


New e-invoicing mobile application

While implementing the Polish e-invoicing mandate, the Polish government will have been acutely aware of the need to construct a system that efficiently facilitates secure and efficient invoice exchange. Concurrently, the government will want to yield a solution that is accessible and user-friendly for taxpayers. To this effect, the Polish government has been advancing new practices for taxpayers to facilitate the issuing and receipt of invoices via the Polish e-invoicing national platform, the KSeF. 


The launch of a new mobile application is expected to accomplish this purpose and is expected to embark in Q1 2024. The application is presumed to serve as an efficient tool to help manage the mandate demands in an efficient and streamlined manner.  


Kofax is supporting the upcoming Polish e-invoicing mandate. You can read more about the upcoming mandate on our dedicated country-specific page here 


French e-invoicing/e-reporting mandate postponement

It is one of the most ambitious, perhaps even courageous, but definitely one of the most intrusive, fiscal and digitsation programmes withing the EU – and it is on everyone’s agenda: the French e-invoicing and e-reporting mandate.

Over the past weeks it became increasingly apparent that the French Directorate General of Public Finance (DGFIP) might be considering delaying the implementation date of the French e-invoicing and e-reporting requirements. The delay was confirmed on July 28 PM via this press release:

The original start date of what we named ‘the French Mandate’ was July 1, 2024. No new dates have been communicated in the press release. The delay raises many questions, including, critically, how the PDP registration will now progress (Plateforme Dematerialisation Partenaire); there will be questions about the market pilot planned to start on January 3, 2024. And there is still the nagging question as to whether we will see further changes to the requirements, which is not uncommon when e-invoicing/e-reporting obligations are delayed. 

Some of the details in the press release, particularly the link to adopting the Finance Law for 2024, could suggest that the delay may be considerable. We will provide more information on the postponement as soon as we learn more.